Further Proposed Modifications to the North Hertfordshire Local Plan 2011- 2031

We have previously objected to your proposal to build 2100 homes on green belt land (East of Luton) and are disappointed to see that, despite all the arguments that have been put forward to dispute the need for these, your Evidence Document ED224 (the Statement of Common Ground between NHDC, Luton Borough Council and Crown Estates) of December 2020 continues to insist that the 2,100 houses proposed around Cockernhoe are necessary to help meet Luton's unmet needs.

It pains us to have to contact you yet again to point out to you that these homes are not necessary and because of this we must register our objection to your documentED224 for the following reasons:

Residents of Cockernhoe, Mangrove Green and Wigmore have carried out a painstaking review of publicly available information on Luton’s house building programme and housing requirements and conclude - with fully supported evidence - that:

• due to significantly increased grants of planning permissions and public announcements, Luton will be building around 14,700 houses through to 2031. compared to 8,500 stated in the LBC Local Plan. These are all on brownfield sites;
• an updated analysis of Luton’s housing needs, carried out by Opinion Research Services in August 2020 at the request of the NHDC Inspector, showed that the previous housing requirement of 17,800 through to 2031 would now be reduced to 16,700;
• these two facts mean the unmet housing need from Luton drops to around 2,000 (16,700 -14,700), compared to 9,300 (17,800-8,500) in the Luton Local Plan;
• the Luton Inspector - when giving the go-ahead for the Luton Local Plan in 2017 - stated that 'the ‘best fit’ for any unmet housing need was Central Beds which has committed to provide 7,350 dwellings'. In fact, it has allocated 20 sites with capacity for at least 8,850 dwellings from which to provide that help. Hundreds of those houses are already built or under construction;
• had Luton carried out its planned Review, these figures would have come to light formally confirming that NHDC does not need to allow development at EOL;
• all this information is known to NHDC and yet it signed a Statement of Common Ground in December 2020 (ED224) with Luton, Bloor Homes and the Crown Estate sticking to the out-of-date numbers to continue justifying its EOL plans. Central Beds - the most important neighbouring local authority to Luton - was not a party to this Statement;
• Finally, there is no evidence at all that NHDC officials and Councillors have carried out adequate, or even any, due diligence on Luton’s housing figures. This causes extreme concern- but we believe our investigations have identified the accurate facts.
We hope that, on reflection, you will give this ill though-out proposal your urgent reconsideration.